Our Position

Deposit Insurance

Position

  • Our nation’s federal deposit insurance system is critical to depositor confidence in the banking system, to the protection of small depositors, and to the funding base of community banks. A strong Deposit Insurance Fund (DIF) is important to maintaining public confidence that the FDIC has adequate resources to protect the nation’s depositors.

  • ICBA commends the FDIC for remaining flexible during the pandemic and establishing a Deposit Insurance Fund Restoration Plan that provides until September 30, 2028 to restore the DIF reserve ratio to 1.35percent. This will allow deposits to return to pre-pandemic levels without increasing insurance assessments.

  • ICBA supported S. 2155 which ensures that reciprocal deposits are not considered brokered deposits under the Federal Deposit Insurance Act.

  • ICBA commends the FDIC for substantially mitigating the impact of SBA PPP lending on FDIC insurance assessments.

Background

Deposit insurance has been the stabilizing force of our nation’s banking system for more than 85 years. It promotes public confidence by providing safe and secure depositories for small businesses and individuals alike.

Deposit Insurance Fund Restoration Plan. The Federal Deposit Insurance Act requires the FDIC to maintain a minimum reserve ratio for the DIF of 1.35 percent and to establish a Deposit Insurance Fund Restoration Plan if the reserve ratio falls below the statutory minimum.

Due to economic stimulus measures enacted in response to the pandemic, and elevated savings rates during this time, quarterly deposit growth rates outpaced deposit growth in the DIF causing the reserve ratio to decline below the required 1.35 percent minimum. ICBA commends the FDIC for establishing a Deposit Insurance Fund Restoration Plan that provides sufficient time and flexibility for the surge of insured deposits to recede and normalize without increasing community bank insurance assessments.

SBA Lending. ICBA commends the FDIC for substantially mitigating the impact of SBA PPP lending on FDIC insurance assessments. For instance, nearly every ratio that determines a small bank’s assessment rate excludes PPP loans because of the FDIC’s recent rule changes.

These ratios include: the net income before taxes to total assets ratio, the nonperforming loans and leases to gross assets ratio, the other real estate owned to gross assets ratio, the brokered deposit ratio, the one-year asset growth measure, and the loan mix index (LMI). Furthermore, the assessment base used to determine assessments excludes PPP loans.

Staff Contact

Christopher Cole

Executive Vice President, Senior Regulatory Counsel

Washington, DC

Email

Jenna Burke

Senior Vice President and Senior Regulatory Counsel

Washington, DC

Email

ICBA Strongly Opposes FDIC Vote on Assessment Rates

Oct. 18, 2022

ICBA Press Release Banner 2020

Agency dramatically raises rates that fund nation’s deposit insurance system

Washington, D.C. (Oct. 18, 2022) — Independent Community Bankers of America (ICBA) President and CEO Rebeca Romero Rainey issued the following statement on today’s FDIC board vote approving an ICBA-opposed proposal to dramatically increase deposit insurance assessments.

“ICBA and the nation’s community banks strongly oppose the FDIC board’s decision to dramatically and uniformly increase the rates banks pay to fund the nation’s deposit insurance system. Today’s vote penalizes community banks and wrongly shifts the burden to community banks to subsidize the systemic risk posed by the nation’s largest banks.

“As ICBA and other groups have stated, the agency’s proposal is based on a faulty assumption that the Deposit Insurance Fund will not meet its minimum level by as late as 2034. In fact, the latest Quarterly Banking Profile suggests the statutory minimum is likely to be satisfied as soon as the first quarter of 2023, obviating the need to raise assessments by more than 50 percent for many community banks.

“This significant rate hike not only disproportionately affects community banks, but it also unnecessarily restricts community bank lending in local communities at a time of economic uncertainty and fails to sufficiently collect enough assessments from the large and complex institutions that pose the greatest risk to the Deposit Insurance Fund. ICBA is profoundly disappointed the FDIC didn’t consider a lower rate hike, the impact on community banks and local communities, or the more than 150 community banker comments submitted opposing the assessment increase.

“ICBA will continue working with the FDIC and urging the agency to advance a more common-sense policy on assessment rates.”

About ICBA

The Independent Community Bankers of America® creates and promotes an environment where community banks flourish. ICBA is dedicated exclusively to representing the interests of the community banking industry and its membership through effective advocacy, best-in-class education, and high-quality products and services.

With nearly 50,000 locations nationwide, community banks constitute roughly 99 percent of all banks, employ nearly 700,000 Americans and are the only physical banking presence in one in three U.S. counties. Holding more than $5.8 trillion in assets, over $4.8 trillion in deposits, and more than $3.5 trillion in loans to consumers, small businesses and the agricultural community, community banks channel local deposits into the Main Streets and neighborhoods they serve, spurring job creation, fostering innovation and fueling their customers’ dreams in communities throughout America. For more information, visit ICBA’s website at www.icba.org.

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Letters to Regulators and Congress

Title Recipient Date
FDIC 10/11/22
FDIC 10/11/22
FDIC 08/20/22
FDIC 08/20/22
FDIC 10/04/21
FDIC 07/09/21
FDIC 06/09/20